Privacy Policy

Effective Date: October 26, 2026 · CloseTraq LLC, a Texas limited liability company

1. Introduction

CloseTraq LLC ("we," "our," or "us") operates CloseTraq at closetraq.com. This Privacy Policy explains how we collect, use, disclose, and protect information about agents and clients who use the Service. By using CloseTraq, you agree to the practices described in this policy.

2. Information We Collect

2.1 Information You Provide Directly

• Account information: name, email address, and password
• Agent profile: brokerage name and contact details
• Transaction data: uploaded contracts, disclosure forms, and addenda
• Client information: names and email addresses of clients invited to view transactions
• Payment information: processed by Stripe, a PCI-compliant payment processor; we do not store full card numbers. Your billing ZIP code (or, without one, your IP address) is used to calculate sales tax
• Communications: support requests or messages sent to us
• Assistant questions: questions you ask the CloseTraq assistant about your transactions, and its answers

2.2 Information Collected Automatically

• Log data: IP address, browser type, pages visited, and timestamps
• Usage data: features used, workflow interactions, and session duration
• Device information: browser version and operating system
• Ad and campaign details: if you arrive from one of our ads or links, the campaign tags in that link and the click identifier an advertising platform adds to it, and, if you create an account after clicking a Meta ad, your browser's user agent

2.3 Information from Third Parties

• AI processing results from documents you upload (via OpenAI and Anthropic)
• Payment status and subscription data from Stripe

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service
• Process transactions and manage subscriptions
• Send transactional emails such as deadline reminders and document notifications
• Send SMS notifications to agents. Text messages go only to agents who agree to them at sign-up or turn them on in Settings, and only after the number is confirmed with a code. Reply STOP to any message to end them
• Respond to support requests and communications
• Review questions asked of the assistant, and its answers, to improve what it can answer
• Measure which of our ads bring agents to CloseTraq, and report sign-ups and first payments to the advertising platform that showed the ad, as described in section 9
• Detect and prevent fraud or unauthorized access
• Comply with legal obligations

4. How We Share Your Information

We do not sell your personal information for money. We do share limited advertising measurement data with Meta and Google, as section 9 explains, and some state privacy laws may classify that sharing as a sale of personal information or as targeted advertising. Phone numbers and text message consent are not shared with third parties or affiliates for marketing. We may share information with:

Service providers, each bound by confidentiality obligations: Supabase (database, file storage, and authentication), Vercel (application hosting), OpenAI and Anthropic (reading your contracts), Anthropic (answering questions in the assistant), Stripe (payments), SendGrid (email), and Twilio (text messages)

• Advertising platforms: Meta Platforms, Inc. (Facebook and Instagram) and Google LLC, each only about agents who arrive from its own ads, as described in section 9
• Legal authorities: when required by law, court order, or to protect the rights and safety of our users
• Business transfers: in connection with a merger, acquisition, or sale of assets, with notice provided to affected users

5. Data Retention

We retain your account information and transaction data for as long as your account is active or as needed to provide the Service. If you close your account, we will delete or anonymize your data within 90 days, except where retention is required by law. Questions asked of the assistant, and its answers, are kept for 12 months and then deleted.

6. Data Security

We implement industry-standard security measures including encrypted data transmission (TLS), private access-controlled cloud storage, and database-level access rules that prevent one agent from reading another agent’s data. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

7. Your Rights

You have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your account and associated data
• Opt out of non-transactional communications
• Opt out of sharing for advertising, by email or with Global Privacy Control, as described in section 9

To exercise any of these rights, contact us at support@closetraq.com.

8. Cookies

CloseTraq uses session cookies to maintain your login state. We do not use third-party advertising cookies, and we do not place advertising pixels or other third-party tracking tags on our site. If you arrive from one of our ads, your browser keeps that link's campaign tags and click identifier in its local storage (not a cookie), the most recent from each advertising platform, so they can be saved with your account if you create one within 30 days. You can disable cookies in your browser settings, but doing so may affect Service functionality.

The walkthrough video is played by YouTube in its privacy-enhanced mode; once you press play, YouTube's privacy policy applies.

9. Advertising

We advertise CloseTraq to real estate agents on Meta (Facebook and Instagram) and Google. To learn which ads work, we keep the campaign tags and click identifier from the ad link that brought you, the most recent from each platform kept separately, and save them with your account if you create one. In our own records, each new account is credited once, to the ad you clicked last.

9.1 What we report, and to whom

Our servers report events directly to Meta Platforms, Inc. and Google LLC. We do not use advertising pixels, tags or cookies on our site to do this. Each platform receives only the events listed for it below, and only about agents who arrived from its own ads. Neither platform receives every event.

• To Meta, only if you arrived from a Meta ad: that you created an account and confirmed your email address, and your first payment to CloseTraq. Later payments, renewals and plan changes are never reported.
• To Google, only if you arrived from a Google ad: that you created an account and confirmed your email address.

If you clicked both a Meta ad and a Google ad before creating your account, each platform may receive its own report of your sign-up. If you did not arrive from either platform's ads, neither receives these reports about you.

9.2 What each report contains

Only the following:

• The click identifier the platform added to its ad link. For Meta, this includes the time you opened that link.
• A unique identifier assigned to the event, so the platform counts it only once.
• What happened (account created, or first payment) and when.
• For Meta, a CloseTraq page address associated with the event, and your browser's user agent (the text your browser sends that names the browser, its version and your operating system).
• For a first payment reported to Meta, its amount before sales tax.

We do not send your name, email address, phone number or IP address. We never send client information, transaction details, property addresses, contracts or other documents, or questions asked of the assistant, and we never send anything about clients.

The click identifier and the event identifier are not your name or email address, but the platform can link them to the ad you clicked and, if you have an account with it, to that account. We treat them as personal information.

9.3 How Meta and Google use it

Meta and Google use these reports to connect the event to the ad click that led to it and to an account on their service if you have one, to measure how our ads perform, to improve how they deliver our ads, and, under their own terms, to personalize the ads and content they show people. Each keeps and uses the reports under its own terms and privacy policy: Meta's at facebook.com/privacy/policy and Google's at policies.google.com/privacy.

9.4 Your choices

You can stop this reporting at any time, in either of two ways:

• Email support@closetraq.com and ask us to stop sending advertising events about you.
• Turn on Global Privacy Control in your browser. We treat the signal as the same request when you create your account and whenever you visit CloseTraq while signed in.

Either way, we stop all future reports about you to both Meta and Google and cancel any not yet sent. Reports already sent stay with the platform under its own policies. Your choice stays in place if you later turn the signal off; to reverse it, email us. You can also control the ads you see in your Meta ad preferences and in Google's My Ad Center.

Some state privacy laws may treat this sharing as targeted advertising or as a sale of personal information. The choices above are how you opt out of it.

10. Children's Privacy

The Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that a minor has provided us with personal information, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the effective date and, where appropriate, by email. Your continued use of the Service after changes take effect constitutes acceptance of the revised policy.

12. Contact

For questions or concerns about this Privacy Policy, contact us at: support@closetraq.com